1

Huntington University

Huntington University

2303 College Ave. Huntington, IN 46750

Nathan Hartman - 260-692-2057

nhartman@huntington.edu

October 6, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington DC 20590

Dear Sir or Madam,

We, Huntington University, are writing pursuant to the FAA Modernization and

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request

an exemption from the Federal Aviation Regulations (“FARs”) listed below so that

We, Huntington University, may operate our small ultra-light weight unmanned

aircraft system (“UAS”) commercially in airspace regulated by the Federal

Aviation Administration (“FAA”).

As described herein Huntington University’s UAV instructor is a certified UAS

pilot in the United States and has experience in flying hobby Quad Copters for

recreational purposes. Our Inventory includes one DJI Inspire 1 with a 4K

camera with the intent for aerial videography/cinematography and UAS training,

enhancing the academic community awareness for those individuals unfamiliar

with UAS flight and abilities; following exemption and approval by the FAA. UAS

specs below:

Inspire 1 Aircraft

• Model: T600

• Weight (Battery Included): 2935 g

• Hovering Accuracy (GPS Mode)

• Vertical: 0.5 m

• Horizontal: 2.5 m

• Max Angular Velocity

• Pitch: 300°/s

• Yaw: 150°/s

• Max Tilt Angle: 35°

• Max Ascent Speed: 5 m/s

• Max Descent Speed: 4 m/s
2

Huntington University

• Max Speed: 22 m/s (ATTI mode, no wind)

• Max Flight Altitude: 4500 m

• Max Wind Speed Resistance: 10 m/s

• Max Flight Time: Approximately 18 minutes

• Motor Model: DJI 3510

• Propeller Model: DJI 1345

• Indoor Hovering: Enabled by default

• Operating Temperature Range: -10° to 40° C

• Diagonal Distance: 559 to 581 mm

• Dimensions: 438x451x301 mm

• Power Spectral Density: 9.06mW/MHz

Inspire 1 Gimbal

• Model: ZENMUSE X3

• Operating Current

• Station: 750 mA

• Motion: 900 mA

• Angular Vibration Range: ±0.03°

• Mounting: Detachable

• Controlable Range

• Pitch: -90° to +30°

• Pan: ±320°

• Mechanical Range

• Pitch: -125° to +45°

• Pan: ±330°

• Max Controllable Speed

• Pitch: 120°/s

• Pan: 180°/s

Inspire 1 Camera

• Name: X3

• Model: FC350

• Total Pixels: 12.76M

• Effective Pixels: 12.4M

• Image Max Size: 4000x3000

• Iso Range

• 100-3200 (video)

• 100-1600 (photo)

• Electronic Shutter Speed: 8s - 1/8000s
3

Huntington University

• FOV (Field Of View): 94°

• CMOS: Sony EXMOR 1/2.3”

• Lens

• 20mm (35mm format equivalent)f/2.8 focus at ∞

• 9 Elements in 9 groups

• Anti-distortion

• Still Photography Modes

• Single shoot

• Burst shooting: 3/5/7 frames

• Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

• Time-lapse

• Video Recording Modes

• UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

• FHD: 1920x1080p24/25/30/48/50/60

• HD: 1280x720p24/25/30/48/50/60

• Max Bitrate Of Video Storage: 60 Mbps

• Supported File Formats

• FAT32/exFAT

• Photo: JPEG, DNG

• Video: MP4/MOV (MPEG-4 AVC/H.264)

• Supported Sd Card Types

• Micro SD

• Max capacity: 64 GB. Class 10 or UHS-1 rating required.

• Operating Temperature Range: 0° to 40° C

Remote Controller

• Name: C1

• Operating Frequency

• 922.7~927.7 MHz (Japan Only)

• 5.725~5.825 GHz

• 2.400~2.483 GHz

• Transmitting Distance (Outdoor And Unobstructed): 2 km

• EIRP: 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

• Video Output Port: USB, mini-HDMI

• Power Supply: Built-in battery

• Charging: DJI charger

• Dual User Capability: Host-and-Slave connection

• Mobile Device Holder: Tablet or Phone

• Max Mobile Device Width: 170mm

• Output Power: 9 W
4

Huntington University

• Operating Temperature Range: -10° to 40° C

• Storage Temperature Range

• Less than 3 months: -20° to 45° C

• More than 3 months: 22° to 28° C

• Charging Temperature Range: 0-40° C

• Battery: 6000 mAh LiPo 2S

Charger

• Model: A14-100P1A

• Voltage: 26.3 V

• Rated Power: 100 W

Battery (Standard)

• Name: Intelligent Flight Battery

• Model: TB47

• Capacity: 4500 mAh

• Voltage: 22.2 V

• Battery Type: LiPo 6S High voltage battery

• Energy: 99.9 Wh

• Net Weight: 570 g

• Operating Temperature Range: -10° to 40° C

• Storage Temperature Range

• Less than 3 months: -20° to 45° C

• More than 3 months: 22° C to 28° C

• Charging Temperature Range: 0° to 40° C

• Max Charging Power: 180 W

Vision Positioning

• Velocity Range: Below 8 m/s (2 m above ground)

• Altitude Range: 5-500 cm

• Operating Environment: Brightly lit (lux > 15) patterned surfaces

• Operating Range: 0-250 cm

Huntington University is committed to safety with each flight. Huntington

University exemption request would permit operation of ultra-light weight,

unmanned (piloted by remote control) and comparatively inexpensive UAS in

tightly controlled and limited airspace. Predetermined in areas away from

general public, airports, heliports, and vehicular traffic for videography and UAS

training purposes.
5

Huntington University

Granting our, Huntington University, request comports with the Secretary of

Transportation’s (FAA Administrator’s) responsibilities and authority to not only

integrate UAS’s into the national airspace system, but to “...establish

requirements for the safe operation of such aircraft systems (UAS’s) in the

national airspace system” under Section 333(c) of the Reform Act. Further we,

Huntington University, will conduct our operations in compliance with the

protocols described herein or as otherwise established by the FAA.

For the reasons stated below, We, Huntington University, respectfully request the

grant of an exemption allowing us to operate ultra-light weight, remote controlled

UAS’s to benefit/stimulate academic awareness on UAS flight, safety,

videography, and agriculture use, which will promote economic growth and

technological advancement through education and training for both individuals

and the community at large. Such training will potentially replace and reduce the

use of heavier manned aircraft containing combustible fuel for videography and

agriculture needs, bringing benefit to overall public safety. UAS use through

training at Huntington University would also decrease the potential of untrained

and unlawful UAS piloting, as the education to the public would increase

awareness of proper UAS safety.

I. Contact Information

Huntington University, Nathan Hartman

2303 College Ave. Huntington, IN 46750

Tele: 260-692-2057

Email: nhartman@huntington.edu

II. The Specific Sections of Title 14 of the Code of Federal Regulations from

Which Huntington University Requests Exemption are...

14 C.F.R. 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91, et seq.; 14 C.F.R. 407 (a) (1); 14

CFR 409 (a) (2); and, 14 C.F.R. 417 (a) & (b).

III. The Extent of Relief Huntington University Seeks and the Reason We

Seek Such Relief

We, Huntington University, submit this application in accordance with the Reform

Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs

operating to prevent we, Huntington University, contemplated commercial

cinematic, academic and other flight operations within the national airspace

system. The Reform Act in Section 332 provides for such integration of civil
6

Huntington University

unmanned aircraft systems into our national airspace as it is in the public’s

interest to do so. Our, Huntington University, ultra-light weight UAS meets the

definition of “small unmanned aircraft” as defined in Section 331 and therefore

the integration of our ultra-light weight UAS is expressly contemplated by the

Reform Act. We would like to operate our light weight UAS prior to the time

period by which the Reform Act requires the FAA to promulgate rules governing

such craft. Thereby, providing direct experience and valuable information for

formal regulation that can be administered uniformly to all related UAS

videography and training.

The Reform Act guides the Secretary in determining the types of UAS’s that may

operate safely in our national airspace system. Considerations include: The

weight, size, speed and overall capabilities of the UAS’s; whether the UAS will be

operated near airports or heavily populated areas: and, Whether the UAS will be

operated by line of sight. 112 P.L. 95 §§ 333 (a). Each of these items reflect in

favor of an exemption for us, Huntington University. Our UAS utilizes four

counter-rotating propellers for balance, control and stability. Our UAS is equipped

with GPS and auto return safety technology. Weighing less than ten pounds (far

below the max. 55 pound limit); including camera and gimbal.

Huntington University, considers safety as foremost with each flight. Our small

unmanned aircraft is designed to hover in place via GPS and operate in less than

13 knot (15mph) wind. For safety, stability and fear of financial loss we will not fly

in winds exceeding 13 knot (15mph). Built in safety systems include a GPS mode

that allows our UAS to hover in place when radio controls are released. No UAS

operations near airports, hospitals nor police heliports, and do not operate near

areas where general public is within fifty to on hundred (50-100) yards depending

on location, conditions and weather. We are constantly on alert for any manned

aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately

to the nearest and safest ground point should a manned aircraft approach our

location or we suspect manned aircraft may approach near our location. Our

UAS is capable of vertical and horizontal operations, and are flown only within

our line of sight, as the remote control pilot. Utilizing battery power rather than

combustible fuels, flights generally last between ten (10) to fifteen (15) minutes,

with an altitude under three hundred (300) feet. We, Huntington University, utilize

a fresh fully charged battery with each flight as a safety precaution; full flight time

limit for each battery in ten (10) to fifteen (15) minutes as tested. We do not

operate our UAS at or below manufacture recommend minimum charge levels for

operation; preferring to remain well within a safe operating range to insure

adequate communication between radio control and UAS to eliminate potential
7

Huntington University

for crash, loss of control or hazard. Reserve batteries are at hand with each

exercise to insure replacement for sufficient safe level of operation. We do not

believe in taking risks that may cause a crash, that could create hazard to the

public/property/manned aircraft, and have no desire to lose an investment. We

have clocked numerous practice flights in remote areas as a hobbyist simulating

flights for commercial use to gain familiarization with the characteristics of this

specific UAS’s performance under different temperature and weather conditions.

We, Huntington University, are extremely cautious when operating our UAS ultralight weight unmanned aircraft and will not “create a hazard to users of the

national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small

size and weight of our UAS it falls well within Congress’s contemplated safety

zone when it promulgated the Reform Act and the corresponding directive to

integrate UAS’s into the national airspace system. Huntington University, used in

hobby flight, has a demonstrable safety record and does not pose any threat to

the general public or national security.

IV. How Huntington University Request Will Benefit the Public As A Whole:

Aerial videography has been around for a long time through manned fixed wing

aircraft and helicopters. These manned aircrafts pose a threat to the public

through potential catastrophic crashes. Our, Huntington University, UAS pose no

such threat since size and lack of combustible fuel alleviates any potential threat

to the public. For companies seeking footage and students desiring to learn

about aerial videography, manned aircraft is also cost prohibitive. Our,

Huntington University, UAS reduces costs to local business and provides a safe

and affordable learning environment for UAV education.

Congress has already proclaimed that it is in the public’s interest to integrate

commercially flown UAS’s into the national airspace system, hence the passing

of the Reform Act. Our, Huntington University, exemption request furthers the

public interest through academic awareness of the potential of UAV technology.

Our ultra-light weight UAS is battery power and creates no emissions that can

harm the environment. The consequences of the ultra-light weight UAS crashing

is far less than a full size helicopter or fixed wing aircraft; which are have, contain

combustible fuel and can cause devastation to the public. The public’s interest is

furthered by minimizing ecological and crash threat by permitting aerial

video/photo capture through our battery operated ultra-light weight UAS’s.

Permitting us, Huntington University, to immediately fly within national air space

furthers economic growth. Granting our exemption requests substantially furthers
8

Huntington University

the economic impact for the local community of companies looking to use aerial

footage and individuals looking to relocate for career advancement through

academic awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Huntington University Exemption Will Not Adversely

Affect Safety or How the Exemption Will Provide a Level of Safety At Least

Equal to Existing Rule:

Our, Huntington University, exemption will not adversely affect safety. Quite the

contrary, for the reasons stated permitting us, Huntington University, to log more

flight time in FAA controlled airspace, with communication with the FAA, will

allow us to contribute to the innovation and implementation of new and novel, as

of yet undiscovered safety protocols to both be used and taught in our academic

setting.

In addition we, Huntington University, submit the following as representations of

the safety of our UAS.

• Our UAS weights less than 20 pounds complete with gimbal and high

resolution cameras.

• We only operate our UAS below 300 fee (well within the 400 foot permissible

ceiling set by the FAA Modernization and Reform Act of 2012).

• Our UAS only operate for 10-15 minutes per flight.

• We land our UAS prior to manufacturer recommended minimum battery levels.

• We pilot our UAS through remote control only by line of sight.

• Our UAS has GPS flight safety features whereby it hovers and then slowly

lands if communication with the remote control pilot is lost.

• We actively analyze flight data and other sources of information to constantly

update and enhance safety protocols.

• We only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas.

• We conduct extensive pre-flight inspections and protocol, during which safety

carries primary importance.

• We always obtain all necessary permissions prior to operation.

Our, Huntington University, safety protocols provide a level of safety equal to or

exceeding existing rules. It is important to note that absent the integration of

commercial UAS into our national airspace system, helicopters are the primary

means of aerial video and photography for community awareness and

instruction. While the safety record of such helicopters is remarkably astounding,
9

Huntington University

the potential loss of life is diminished as UAS’s do not carry people on board and

we only operate our UAS in specific areas away from mass populations. There is

also no fuel on board a UAS and thus the potential for fire or explosions is greatly

diminished. Lastly, the small size provides extreme maneuverability out of any

potential danger.

Accordingly, our UAS has been experimentally operated for

familiarization/competency and will continue to operate at and above current

safety levels.

VI. A Summary The FAA May Publish in the Federal Register

14 C.F.R. 21 & 14 C.F.R. 91: Airworthiness Certificates, Manuals and the like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation

to FAR § 91.203 (a) (1). The size, weight and enclosed operational area of our,

Huntington University, UAS permits exemption from Part 21 because our UAS

meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft form the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section

333 of the Reform Act.

Both pieces of legislation permit the FAA to exempt UAS’s from the airworthiness

certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to area such as airports and dense populations.

Our, Huntington University, current and projected UAS’s meet or exceed each of

the elements.

14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there

are no on board pilots or passengers, and given the size of the UAS’s, this

Regulation is inapplicable. An equivalent level of safety will be achieve by

maintaining our, Huntington University, safety protocols and having the UAS

manual in the possession of the remote pilot. The FAA has previously issued

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A,

9565, 9565B, 10167, 10167A, 10602, 10700, and 32827.
10

Huntington University

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our

UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft

certifications and registrations. They are inapplicable for the same reasons

described above. The equivalent level of safety will be achieved by maintaining

any such required certifications and registrations by us, Huntington University.

14. C.F.R. § 45.23: Marking of the Aircraft

Applicable Codes of Federal Regulation require aircraft to be marked according

to certain specifications. Our UAS are, by definition, unmanned. They therefore

do not have a cabin, cockpit, or pilot station on which to mark certain words or

phrases. Further, two-inch lettering is difficult to place on such small aircraft with

dimensions smaller that minimal lettering requirement. Regardless, We will mark

our UAS in the largest possible lettering by placing the word “EXPERIMENTAL”

on its fuselage as required by 14 C.F.R. § 45.29 (f) so that we the pilot, or

anyone assisting as a spotter with the UAS will see the markings. The FAA has

previously issued exemptions to this regulation through Exemptions Nos. 8738,

10167, 10167A and 10700.

14 C.F.R. 91.119: Minimum Safe Altitudes

14 C.F. R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It

allows helicopters to be operated at lower altitudes in certain conditions. Our

UAS will operate at altitude at or lower than 300 AGL; safely below the standard

400 AGL. We, Huntington University, will however operate our UAS in safe areas

away from public and traffic, providing a level of safety at least equivalent to

those in relation to minimum safe altitudes. Given the size, weight,

maneuverability and speed of our UAS, an equivalent or higher level of safety will

be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance

Inspections

The above-cited regulations require, amongst other things, aircraft owners and

operators to “have the aircraft inspected as prescribed in subpart E of this part

and shall between required inspections, except as provided in paragraph (c) of

this section, have discrepancies repaired as prescribed in part 43 of this

chapter...”

These regulations only apply to aircraft with an airworthiness certificate. They will

not, therefore, apply to our, Huntington University, UAS. However, as a safety
11

Huntington University

precaution we inspect our UAS before and after each flight as well as maintaining

a maintenance log.

In Summary, Huntington University seek an exemption from the following

regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R.

§91.9 (b) (2); 14 C.F.R. § 91.103 (b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a) (2); 14

C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b)

Exemption would allow us to commercially operate our, Huntington University,

small unmanned vehicle/lightweight unmanned aircraft vehicle in community

awareness, videography, and education. Currently, area such tasks are primarily

done through larger manned aircrafts running on combustible fuel. Our UAS craft

do not contain potentially explosive fuel, are smaller, lighter and more

maneuverable than conventional manned videography aircraft. Granting our,

Huntington University, request for exemption will reduce current risk levels and

thereby enhance safety.

We, Huntington University, have been informally analyzing flight information and

will compile safety protocols and the implementation of a flight operations manual

for videography and training usage that exceeds currently accepted means and

methods for safe flight. Formal collection of information shared with the FAA will

enhance the FAA’s internal efforts to establish protocols for complying with the

FAA Modernization and Reform Act of 2012. There are no personnel on board

our, Huntington University, UAS and therefore the likelihood of death or serious

bodily injury is significantly diminished.

Our, Huntington University, operation of our UAS, weighing less than 20 pounds

and traveling at lower speeds within limited areas will provide an equivalent level

of safety as that achieved under current FARSs. Accordingly We, Huntington

University, respectfully request that the FAA grant our exemption request and are

willing to cooperate in sharing the information to benefit the FAA, safety of

manned aircraft, and the general public at large.

Respectfully submitted,

Nathan Hartman

Huntington University - 2303 College Ave. Huntington, IN 46750